§ 32.29A IRREGULAR VARIANCES, LOSSES AND SHORTAGES; THEFTS.
   (A)   Purpose. This policy is intended to comply with the provisions of IC 5-11-1-27, and State Examiner Directive 2015-6 issued November 18,2015, each as currently in effect, or amended hereafter from time to time.
   (B)   Materiality threshold.
      (1)   (a)   The materiality thresholds for the town shall be as follows:
            1.   Governmental activities and sewer utility - $3,000.
            2.   Water utility - $ 1,000.
            3.   Storm water utility - $500.
         (b)   If the irregular variance, loss or shortage is not cash or a cash-equivalent, the value of the item at the time of the variance, loss or shortage shall be used to determine whether the materiality threshold has been met.
      (2)   All irregular variances, losses or shortages exceeding the above thresholds shall be reported upon completion of the bank reconciliations or within 30 days of the monthly accounting period closing, whichever occurs first, to the State of Indiana Board of Accounts. In addition, irregular variances, losses or shortages which occur more often than four times in a month and which in the aggregate total the amounts indicated above shall be reported immediately to the State of Indiana Board of Accounts.
      (3)   Any theft of public funds or assets of any value upon discovery, shall be immediately reported to the State of Indiana Board of Accounts and the Office of the Lake County Prosecuting Attorney.
   (C)   Knowledge of misappropriation. A public officer who has knowledge of or reasonable cause to believe that there has been a misappropriation and/or theft of public funds or assets of the public office shall immediately send written notice of the misappropriation and/or theft to the State of Indiana Board of Accounts and the Office of the Lake County Prosecuting Attorney.
   (D)   Maintenance of documentation. The town shall maintain records and documentation concerning irregular variances, losses, shortages and thefts in accordance with generally-accepted accounting principles and the required minimum internal control standards established as required by the State of Indiana Board of Accounts.
   (E)   Resolution of incidents not meeting the materiality threshold. The town shall immediately, upon discovery, investigate all irregular variances, losses, or shortages regardless of whether such meet the materiality threshold established by this town policy. Upon conclusion of each such investigation, the town shall:
      (1)   Implement procedures designed to prevent the recurrence of such incidents; and
      (2)   Take appropriate disciplinary action against the employee(s)/town official(s) responsible for the incident.
(Ord. 1234A, passed 6-7-16)